ISDA published a set of best practices for central counterparties (CCPs) to ensure greater consistency in risk practices at CCPs across the globe. The paper highlights steps that can be taken to minimize the potential for a member default to impact other members and the financial system as a whole, except in an extreme stress event.
The paper recommends that CCP risk management decisions be based on the risk profile of a product, rather than on whether a derivative is an exchange-traded or over-the-counter (OTC) product. Other best practice recommendations include ensuring CCPs have risk controls and margin requirements that adapt to concentration, liquidity, member credit quality, and wrong-way risk in a member’s portfolio. CCPs should also have effective and transparent default management processes and robust membership criteria. The paper sets out the following best practices:
- Risk management must be aligned with the underlying risk of a given product.
- CCPs must have robust membership requirements that are regularly reviewed.
- Products cleared by a CCP must be sufficiently standardized and liquid.
- CCPs must ensure they have a sufficient number of members to mutualize risk.
- Margin must be calculated consistently across all products, taking account of concentration, liquidity, and wrong-way risk.
- Controls should be used to protect against erroneous trades and the build-up of concentrated positions.
- Key documentation must be disclosed, including margin and stress testing models and default management procedures.
- The size of the default fund should be aligned with key best practices, with limits on the portion of the default fund that can be consumed by any one member.
- The default management process should include key elements—for instance, ensuring sufficient participation in auctions—and should be tested regularly.
- Parties underwriting the counterparty risk of a CCP should be part of its governance.
Keywords: International, Securities, CCP, OTC Derivatives, Systemic Risk, Margin Requirements, ISDA
Across 35 years in banking, Blake has gained deep insights into the inner working of this sector. Over the last two decades, Blake has been an Operating Committee member, leading teams and executing strategies in Credit and Enterprise Risk as well as Line of Business. His focus over this time has been primarily Commercial/Corporate with particular emphasis on CRE. Blake has spent most of his career with large and mid-size banks. Blake joined Moody’s Analytics in 2021 after leading the transformation of the credit approval and reporting process at a $25 billion bank.
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